Tony Beare (Slaughter and May) examines the recent eagerly anticipated First-tier Tribunal decision of Next Brand Ltd v HMRC on dividend boosters.
The US Treasury is consulting on draft revisions to its Model Tax Convention, aimed at maintaining a consistency of approach to base erosion and profit shifting by multinational companies with that of the G20/OECD BEPS action plan.
HMRC has issued guidance on how it will treat holding companies and treasury companies for the purposes of the UK’s agreements on FATCA and automatic exchange of financial information, following the announcement in March that such companies no longer come within the definition of foreign financia
The flat-rate taxation of investments and EU law
The staggered payment of an exit charge and EU law
Australia, like the UK, has announced new measures countering the diversion of profits by multinationals, writes Heather Self (Pinsent Masons). The measures increase the pressure on the US to engage with the OECD’s BEPS project.
The definition of investment entities under FATCA, under the model IGA and under the UK IGA, regulations, guidance notes varies in important respects. Andrey Krahmal (Temple Tax Chambers) provides a summary of how the rules apply to investment entities most frequently encountered in practice.
The Jersey government is consulting tax agents on a number of options for changing the tax rules on distributions from Jersey resident companies, including extending the rules to Jersey trustees.
The European Parliament Special Tax Rulings Committee held a meeting on 11 May with the International Consortium of Investigative Journalists (ICIJ) to share their experiences on the November 2014 ‘Luxleaks’ revelations, where members of the European Parliament (MEPs) complimented them on their ‘
The OECD invites comments by 12 June 2015 on a new discussion draft for action 7 of the BEPS action plan (see www.bit.ly/1HmYCwj). This reflects comments received on the first discussion draft published in October 2014.